Early medical abortion at home: consultation

3. Consultation Questions

24. Based on the evidence so far, while there are some additional risks due to not having an appointment in person, the Scottish Government is satisfied, following discussions with Scottish Abortion Care Providers, that these risks are low and are outweighed by the risks of spreading the virus if all women had to have in person appointments. Therefore, given that most women prefer to remain at home where possible, we are comfortable that the current approval remains appropriate while COVID-19 poses a significant risk to public health in Scotland. 25. However, it is now an appropriate time to start considering future arrangements for abortion services in the longer term. Initial feedback suggests some NHS Boards would like to continue to permit women to take mifepristone at home without an in person appointment to make abortion services easier to access, particularly for those who find it difficult to travel to a hospital clinic for an appointment for any reason. For example, research highlights difficulties for some women in accessing abortion care in remote and rural Scotland^[10]. However, we are aware that some people have concerns that there are a number of risks in not having in person appointments. In particular they feel there are risks that women may underestimate the gestation of their pregnancy and that services may be less likely to detect if women are victims of domestic abuse or human trafficking if they do not see the woman in person. 26. Therefore we would be grateful for responses to the following questions to help inform decisions on future policy. You do not need to answer all the questions if you don't want to. Where you have evidence or other information which may be useful, you can provide brief text comments to supplement your answer. This consultation will be open until 5 January 2021.

Question 1. What impact do you think that the current arrangements for early medical abortion at home (put in place due to COVID-19), have had on women accessing abortion services? Please answer with regards to the following criteria:

a) safety

• No impact
• Positive impact
• Negative impact
• The impacts are mixed
• I don't know

b) accessibility and convenience of services

• No impact
• Positive impact
• Negative impact
• The impacts are mixed
• I don't know

c) waiting times

• No impact
• Positive impactNegative impact
• The impacts are mixed
• I don't know

Comments (optional):

Question 2. What impact do you think that the current arrangements for early medical abortion at home (put in place due to COVID-19), have had for those involved in delivering abortion services? (For example, this could include impacts on workforce flexibility and service efficiency.)

• No impact
• Positive impact
• Negative impact
  
• The impacts are mixed
• I don't know

Comments (optional):

Question 3. What risks do you consider are associated with the current arrangements for early medical abortion at home (put in place due to COVID-19)? How could these risks be mitigated?

Comments:

As part of this consultation, we also wish to consider the likely or possible impacts (both positive and negative) on different groups of women, of allowing the current arrangements to continue permanently. This includes women who share a protected characteristic as defined by the Equality Act 2010^[11], including disabled women, younger women, minority ethnic women and women who share a particular religion or belief, as well as women who have childcare or other caring responsibilities. We also wish to consider the likely or possible impacts (both positive and negative) on trans men who require access to abortion services, of allowing the current arrangement to continue.

Question 4. Do you have any views on the potential impacts of continuing the current arrangements for early medical abortion at home (put in place due to COVID-19) on equalities groups (the protected characteristics of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation)?

• Yes
• No
• I don't know

If yes, please outline possible impacts below. Please be as specific as you can and include any resources or references to evidence on this topic that we should consider.

In addition to the groups discussed above, we also want to seek views on the potential for making permanent home use of both pills for early medical abortion to reduce or increase inequality in health outcomes experienced by different socio-economic groups. This is in particular to help ensure we meet our responsibilities under the Fairer Scotland Duty^[12] to help tackle inequalities caused by socio-economic disadvantage.

Question 5. Do you have any views on potential impacts of continuing the current arrangements for early medical abortion at home (put in place due to COVID-19) on socio-economic equality?

• Yes
• No
• I don't know

If yes, please outline possible impacts below. Please be as specific as you can and include any resources or references to evidence on this topic that we should consider.

Question 6. Do you have any views on potential impacts of continuing the current arrangements for early medical abortion at home (put in place due to COVID-19) on women living in rural or island communities?

• Yes
• No
• I don't know

If yes, please outline possible impacts below. Please be as specific as you can and include any resources or references to evidence on this topic that we should consider.

Whether to make current early medical abortion arrangements a permanent measure

As set out above, we are seeking views on whether the current flexibilities should be made permanent or not.

Question 7. How should early medical abortion be provided in future, when COVID-19 is no longer a significant risk? [select one of the options below]

a) Current arrangements (put in place due to COVID-19) should continue – in other words allowing women to proceed without an in person appointment and take mifepristone at home, where this is clinically appropriate.

b) Previous arrangements should be reinstated – in other words women would be required to take mifepristone in a clinic, but could still take misoprostol at home where this is clinically appropriate.

c) Other (please provide details) –